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Anti-Money Laundering & Counter-Terrorist Financing Operating Policy


Enterprise Compliance Framework  |  Effective Date: January 2026


Policy Structure & Index
  1. Institutional Commitment & Governance Mandate
  2. Statutory & Regulatory Architecture
  3. Institutional Risk Management & RBA Controls
  4. Customer Identification & Due Diligence (CDD/KYC)
  5. Enhanced Due Diligence (EDD) Protocols
    • 5.1 Politically Exposed Persons (PEPs) Supervision
    • 5.2 High-Risk Customer Escalations
  6. Continuous Transaction Oversight & Activity Monitoring
  7. Data Integrity, Audit Trails & Document Retention
  8. Enterprise Compliance Education & Staff Awareness

1. Institutional Commitment & Governance Mandate

Wavetop Global is committed to maintaining absolute zero tolerance for financial crime, illegal asset movement, and terrorism funding. The company fully complies with all governing Nigerian Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) acts, statutory instruments, and regulatory directives.

Operational Scope: This Policy binds all operational units, executives, board members, standard employees, foreign correspondent institutions, agents, and third-party contractors acting on behalf of Wavetop Global.

Core Legal Definitions:

  • Money Laundering (ML): Any action designed to convert, conceal, or integrate illicit proceeds derived from predicate criminal offenses (including narcotics, fraud, human exploitation, currency forgery, and organized crime) into legitimate financial channels.
  • Terrorist Financing (TF): The provision, solicitation, or management of capital, directly or indirectly, with the intention or awareness that such capital supports terrorism, extremist entities, or sanctioned persons.

To preserve enterprise integrity, Wavetop Global maintains established internal control systems, mandates staff education, and maintains direct operational alignment with law enforcement and regulatory authorities. Engagement with blacklisted entities or non-cooperative jurisdictions is strictly prohibited.

2. Statutory & Regulatory Architecture

Wavetop Global structures its AML/CFT compliance infrastructure directly upon the statutory statutes of Nigeria and international supervisory frameworks, including:

  • Money Laundering (Prevention and Prohibition) Act, 2022
  • Terrorism (Prevention and Prohibition) Act, 2022
  • Nigerian Financial Intelligence Unit (NFIU) Act, 2018
  • Economic and Financial Crimes Commission (EFCC) Act, 2004
  • Central Bank of Nigeria (CBN) AML/CFT/CPF Regulations (including Customer Due Diligence Guidelines & PEP Notes)
  • Securities and Exchange Commission (SEC) AML/CFT Regulations
  • Special Control Unit Against Money Laundering (SCUML) Directives
  • FATF 40 Recommendations and applicable United Nations Security Council Sanctions Guidelines.

3. Institutional Risk Management & RBA Controls

Wavetop Global implements a dynamic Risk-Based Approach (RBA) to identify, rate, and manage potential financial crime exposure across products, geographies, client segments, and transaction methods.

Risk Tiering Matrix

Counterparties are continuously evaluated and assigned a risk tier—Low Risk, Medium Risk, or High Risk—at account creation and throughout the customer lifecycle based on quantitative and qualitative risk scoring.

Automatic High-Risk Classifications

Clients are automatically categorized as High Risk and routed for immediate Enhanced Due Diligence (EDD) under any of the following circumstances:

  • Domicile or operational links in non-compliant, sanctioned, or FATF-monitored jurisdictions
  • Opaque beneficial ownership structures, complex shell arrangements, or hidden Ultimate Beneficial Owners (UBOs)
  • Direct ownership, direction, or involvement by Politically Exposed Persons (PEPs) or their associates
  • Prior enforcement action, negative public news, or criminal investigation regarding financial impropriety
  • Non-resident client status without substantiated domestic commercial necessity
  • Accounts belonging to Non-Governmental Organizations (NGOs), trusts, or charities receiving unstructured donations
  • Transactions exhibiting high complexity, abnormal scale, or absence of transparent economic purpose.

4. Customer Identification & Due Diligence (CDD/KYC)

Verified identity verification forms the foundation of Wavetop Global's defensive controls. Prior to initiating any account setup or single financial operation, the company executes rigorous Customer Due Diligence (CDD) procedures to:

  • Validate the corporate or individual identity using independent legal documentation.
  • Identify all Ultimate Beneficial Owners (UBOs) holding effective controlling equity or voting interest.
  • Determine the standard purpose and baseline financial scope of the customer relationship to enable intelligent ongoing oversight.

5. Enhanced Due Diligence (EDD) Protocols

5.1 Politically Exposed Persons (PEPs) Supervision

Due to elevated vulnerabilities surrounding corruption and public fund diversion, all accounts linked to PEPs receive specialized compliance oversight.

  • PEP Definition: Any individual current or previously holding a prominent public function (within the last 12 months) under a domestic government, foreign state, or international organization, as well as their immediate family members and close associates.
  • Mandatory Controls:
    • Senior Executive Management approval must be obtained before establishing or maintaining a PEP account.
    • Compliance teams must independently verify both the Source of Wealth (SoW) and Source of Funds (SoF) prior to processing activity.
    • Accounts remain subject to continuous, prioritized transaction review throughout their active lifecycle.

5.2 High-Risk Customer Escalations

For high-risk client relationships or atypical product usage, Wavetop Global applies intensified EDD measures, requiring:

  • Mandatory collection of expanded background intelligence, including related entity ties and financial statements.
  • Formal executive sign-off prior to account opening or continuation.
  • Higher frequency baseline updates and tighter transaction monitoring parameters.

6. Continuous Transaction Oversight & Activity Monitoring

Wavetop Global deploys dynamic transaction monitoring tools to review account activity against established behavioral profiles.

Key Surveillance Metrics

Monitoring systems evaluate:

  • Unusual volume spikes, rapid fund throughput, or atypical payment frequencies.
  • Transactions involving high-risk geographic corridors or uncharacteristic routing.
  • Sudden, unexplained changes in corporate turnover, business focus, or operational ownership.

Any transaction lacking verified economic purpose or exhibiting suspicious indicators is escalated to the Compliance Officer for immediate investigation and, where legally mandated, reporting to the Nigerian Financial Intelligence Unit (NFIU).

7. Data Integrity, Audit Trails & Document Retention

Wavetop Global maintains security and data retention controls to prevent record loss, alteration, or unauthorized inspection.

Record Archiving Requirements

  • Retention Horizon: All identity documents, account files, corporate correspondence, transaction logs, and verification records are safely archived for a minimum of five (5) years following account closure or transaction completion.
  • Audit Capability: Retention systems guarantee full transaction reconstruction capabilities to support internal audit functions and legal regulatory inquiries.

8. Enterprise Compliance Education & Staff Awareness

Wavetop Global conducts mandatory, continuous AML/CFT training programs for all employees upon onboarding and on an ongoing annual basis.

Training Objectives

  • Educate personnel on statutory compliance standards, typologies, sanction evasion patterns, and red flags.
  • Deliver specialized, role-tailored instruction for onboarding specialists, compliance analysts, operational officers, and executive leaders.
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